NOCASE sent me the most recent press release; pertaining to the aftermarket/third-party additions to helmets. Here it is in full;
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Certification to NOCSAE Standards and Add-on Helmet Products
OVERLAND PARK, Kansas – August 8, 2013 – The National Operating Committee on Standards for Athletic Equipment (NOCSAE) has released the following statement regarding equipment certified to NOCSAE standards and add-on helmet products.
“Products designed to be added to a football helmet are being marketed and sold; some are intended to measure impacts, while others are expressly marketed as improving a helmet’s performance. Some products claim the ability to protect against concussions. Regardless of the truth of such claims, the addition of those products to a certified helmet changes the model, by definition, under the NOCSAE standards.
“For many years NOCSAE standards have defined a helmet model as a helmet “intended to be identical in every way, except for size.” Any changes, additions or alterations of the model, except for size, color or graphics, even if made by the original manufacturer, require that a new model name be created and a separate certification testing process begin for that new model. This concept of limiting certification to a specific model is commonly found in national and international helmet standards.
- NOCSAE itself does not certify any product, it does not “approve” or “disapprove” of any product, and has no authority to grant exemptions or waivers to the requirements imposed by the standards it writes.
- The addition of an item(s) to a helmet previously certified without those item(s) creates a new untested model. Whether the add-on product changes the performance or not, the helmet model with the add-on product is no longer “identical in every aspect” to the one originally certified by the manufacturer.
- When this happens, the manufacturer which made the original certification has the right, under the NOCSAE standards, to declare its certification void. It also can decide to engage in additional certification testing of the new model and certify the new model with the add-on product, but it is not required to do so.
- Companies which make add-on products for football helmets have the right to make their own certification of compliance with the NOCSAE standards on a helmet model, but when that is done, the certification and responsibility for the helmet/third-party product combination would become theirs, (not the helmet manufacturer). That certification would be subject to the same obligations applicable to the original helmet manufacturer regarding certification testing, quality control and quality assurance and licensure with NOCSAE.
- Products such as skull caps, headbands, mouth guards, ear inserts or other items that are not attached or incorporated in some way into the helmet are not the types of products that create a new model as defined in the NOCSAE standards and are not items which change the model definition.”
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I read it simply as this;
- If companies want to sell equipment that alters the original tested/certified helmet THEY or the individual must re-certify each helmet model it is placed on – adult and youth separate but not sizes.
- After re-certification the third-party is now responsible for the liability of the helmet, basically indemnifying the helmet maker at NOCSAE
- And as we have discussed any product that does not alter the padding or helmet is not under this clause.
I know some are not happy with this decision and even MomsTEAM has clearly stated that this action may slow down progress and innovation when it comes to helmet sensors, but from a business and legal sense this is a card that NOCSAE must play. And before people start thinking conspiracy theory here; the helmet manufacturers were not part of this – but don’t think for a second this is not good news for them. I keep using the analogy of your vehicle; if you add aftermarket items to your transmission or engine it voids the warranty. Think about it, if you made a product with certain guarantees would you be willing to keep liability for that product if someone slapped something on it that you didn’t make?
Also I have not read anywhere where this will be deemed “illegal” and helmets cannot be worn if there is not the re-certification, all this means is that if one gets injured and wants to involve NOCSAE or the helmet makers in litigation and an aftermarket product was affixed to the helmet they are distancing themselves and pushing the liability on the new product/company. Which is quite a risk one of these smaller companies must either accept or protect against.
Why would it be fair for any company to ride the legal shield of helmet makers or NOCSAE in the event of catastrophic injury, shouldn’t they have to be part of the protection plan as well?
If companies don’t have the resources to test the helmets and their products added on then they will have to innovate new ideas. Perhaps taking a step back is not so bad, but we will see…
The Concussion Blog 
NOCSEA has been criticized for conflicts of interest and being too concerned about limiting liability. There’s a huge difference between looking at an organization, it’s funding and inherent conflicts of interests and engaging in far flung conspiracy theories. There’s also a reason antitrust laws exist, and I happen to believe MomsTEAM brought up some very good points for consideration if we all truly want safety to be the primary objective for helmet certification.
A benefit of the various concussion lawsuits is that they are drawing attention to areas where changes could result in improvements in safety. NOCSEA may be an organization that is ripe for change.
Currently the certification of compliance with NOCSAE standards is made by the manufacturer, which is the same process that the CPSC employs for certification of bicycle helmets.
The certification issue has nothing to do with whether an add-on product improves the performance of the helmet, or whether the product even works as advertised. The addition of a product to the helmet model is a change to the model as defined in the standards. If the original helmet manufacturer had made the same change, even with its own product, it would have been required to develop a separate support dataset of certification testing for that “new model”. And a youth version of a model is not the same model as the adult version, unless the only difference is size, color and graphics. If the youth model uses different materials in the padding or shell, it must have its own supporting set of certification testing data.
One other potential problem is the circumstance where more than one add-on product is incorporated into the helmet after certification. Who can vouch for the certification of a helmet with four separate add-on products installed, none of which were, singularly or in combination, part of the original certification testing and QA/QC controls?
Maintaining the integrity and reliability of any helmet standard is directly related to maintaining athlete safety.
Let’s put this into a little bit of perspective. These impact sensors that adhere to a helmet either on the inside or outside weigh less than 2 ounces.If a football helmet cannot stand up to the weight of two or one, or even less than 1 ounce then we have real problems with these helmets don’t we? And, If a football helmet manufacturer can’t tell us that their helmets can hold something that is less than 2 ounces them will someone explain to me why padded decals that weigh four ounces are routinely applied to a football helmet? And, Parents how many of you have applied a light to the front or the back of your child’s bike helmet to keep them safe? These lights weigh about a total of 3 ounces each. Now if you are like me you may have even Adhered a mirror to the helmet and that weighs about an ounce just like the football helmet sensors. So in this situation, parents will need to be the decision-makers. Do we want to do all we can to monitor for a potential concussion? Or, should we pull kids out of football because we are not allowed to stick a 1 ounce piece of plastic on a helmet to monitor for possible concussions. Sports parents are very wise and they can and will demand that Unless they can monitor a child for concussions then their children will no longer play the sport of football.
Speaking of bicycle helmets, after reading “Senseless” at bicycling.com, I’m not sure how comfortable I am with the current CPSC standard. It’s great that helmets help protect against catastrophic injuries, but once again there seems to be resistance to updating the testing standard, as well as difficulties with figuring out how to address rotational forces. Based on a recent paper released by Dr. Charles Tator, concussions, especially repeated concussions, are now being recognized as an important public health risk, so hopefully we’ll eventually see innovations to reduce concussive forces.
“Why NFL Helmets Will Never be Concussion Proof” at fastcodesign.com and the Biokinetics Report on Performance Standards linked in ESPN’s Outside the Lines and PBS Frontlines May 2013 article “Report Warned Riddell about Helmets,” were eye-opening reads. I don’t think the average parent fully understands the difference between linear and rotational forces (as they pertain to concussive injuries), or realizes what helmets can and can’t do.
A week or so ago, I stumbled across a 2011 article in The Seattle Times entitled “Football helmet testing lab anticipates safety questions.” Apparently Halstead was expecting that he could get a call any day from federal investigators looking into football helmet safety. According to the article, it didn’t seem so much as though he thought there was anything wrong with the helmets, but rather that the helmet companies didn’t do an adequate job of telling athletes, coaches or parents exactly what helmets can and can’t do.
I certainly know I had no real understanding of the risks or helmet limitations when I signed my son up for youth football. And, to be honest, I’m not sure if anyone has a good understanding of the risks involved in youth football because there have been so few studies to date. As far as I know, Duma’s 2012 youth impact study was the first one of its kind (it actually seems somewhat shameful that the youngest players were ignored for so long, there are lots of 12 to 15-year-olds and under sustaining concussions, as highlighted by the report released by Safe Kids). Thankfully, Duma’s first youth study prompted changes to youth football practices which will hopefully keep kids safer. Based on Duma’s most recent youth study, the league which implemented practice limitations apparently had significantly less impacts over the season. And, even though sensors have their limitations and we don’t know how many impacts are too many, my guess would be the fewer the better.
As for helmet add-ons, to a certain extent I understand NOCSEA’s concerns. It does seem odd, however, that the release wasn’t sent out until recently. It hasn’t really been a secret that companies were either already marketing add-ons or in the development and testing phase for some time (some products had significant media exposure for over a year). There just seems to be something unfair about waiting until equipment orders had been or were being placed for the upcoming season to publish the new requirements.
Obviously, add-on companies shouldn’t make safety claims which can’t be substantiated, and hopefully the FTC can motivate companies to avoid misleading claims and deceptive practices. I don’t think anyone would want to see a product added to a helmet which could possibly result in harm to the player.
However, I had hoped the availability of affordable sensors would facilitate more impact studies at the youth level as well as provide parents with the option to have some understanding of the impacts their kids are being expose to. It could be important to know if youth players are sustaining 100 or 500+ impacts per season. If kids are sustaining 500+ impacts/season (and, I think Duma’s study had a high of 585 impacts for one player), it might be more important to implement restrictions on the number of practices and games allowed per season.
We probably also need more information about impact locations and the g forces resulting in concussion for youth players. The g forces listed for documented concussions in Duma’s study seemed pretty low (26 g, 58 g, & 64 g +/- 4-10), but there were only a few of them, so it’s difficult to draw conclusions. If researchers are limited to studying 3 or so youth teams per season, it could take a long time to get a better understanding of possible thresholds and exposures for various age ranges. And, that information might be needed to determine if any changes are necessary for youth helmets and/or play/practice rules to reduce the risks young players are exposed to.
Let’s put this into perspective. There are currently five impact sensors that adhere to the inside or outside of a football helmet. Each weighs less than 2 ounces, each with great technology and only getting better for monitoring our kids. The bigger question NOCSAE should be asking the helmet manufacturers should be: “why would a 2 ounce piece of plastic that is adhered to your helmet models have you worried? Can’t your 4.5 pound helmet hold up to a piece of plastic or are you truly worried about the integrity of your helmet”?
The recent NOCSAE “decision” is certainly a nice boost for the helmet manufacturers who each may be exploring their own impact sensor as has Riddell with their new InSite that applies to the inside shell, but clearly it doesn’t keep the path clear towards any new safety measures for our kids, which the sensors are a great step in the right direction.
Parents routinely apply small plastic lights to the front and back of their child’s bike helmets that flash during the day and night. These weigh about 2-3 ounces. If a helmet company told them it voids the warranty do you think they would listen? No, they are smart enough to know that an add-on that kids their child safer is a better risk than if the helmet cracks. Heck, I have a 1,7 ounce mirror on my bike helmet and a light in the front and back for a total of 6.2 ounces. Many kids have the same and these measures keep the kids safer.
One of our readers has also asked “do the helmet makers know that sensors are used in other industries to make products safer? The auto industry has been using sensors in crash test dummies for decades; today’s crash test dummies have almost 200 sensors”!
This begets the question…aren’t our kids worth it? Would you buy a car today if its safety standards were from 1973? If the technology was 40 years old? Clearly, we wouldn’t – but they want us to by helmets for our children that ARE.”
Parents and school boards will need to be the ultimate decision makers on whether they apply a 2 ounce piece of plastic or whether they guess at how many kids may have sustained a serious hit and will also be betting that those heavy helmets can handle a tiny piece of plastic.
And, most important, after following a football team of High School boys for the filming of THE SMARTEST TEAM coming up on PBS, I got to really know these rugged teenage boys. If given the choice; they will ask for the sensors on their helmets or other ways to be tracked for potential concussions. Imagine what they will say when I tell them the helmet companies do not think a 2 ounce piece of plastic will maintain the integrity of the shell?
When the helmet was originally tested for certification of compliance with the NOCSAE standards, it was done in a specific condition and configuration. Any change in that configuration, other than size, color, and graphics, requires a separate set of supporting certification test data. If the original manufacturer had decided to put sensors in a helmet model, it would have been required to create a new and separate set of certification test data to support that certification. The NOCSAE standards do not prevent the inclusion of sensors or other add on products as part of the certification process. A new helmet can be certified by the manufacturer with such a device attached. But that decision is made by the manufacturer certifying the helmet, not by NOCSAE.
For purposes of discussion, the the sensors at issue are described as 2 oz items that can’t hurt the helmet. What rule or standard limits the number, location, dimension, and total mass of these add-ons? Is it ok to add 6 sensors at 2 ounces each? Do the sensors contact the head if the padding is compressed enough over the sensor? Do they create point loading and stress risers on the shell if they are impacted directly during a game? Should the sensors be limited to the locations on the outside of the helmet, or is it OK to place sensors in between the padding inside the helmet? Or both at the same time? And should sensors be used with an outer helmet covering that adds an additional 7-9 ounces? And with some added inside padding supplementation for another 2-4 ounces? At what point is it proper to become concerned about whether the things we’ve added to the helmet may start to interfere with performance?
The average youth helmet mass is 56 ounces. Adding the items above in some combination could increase the helmet mass by 35%. Is that acceptable?
While I was producing the new documentary THE SMARTEST TEAM: Making High School Football Safer- we made sure we had comprehensive testing of a certain sensor by the helmet manufacturer they were being applied to. The sensors passed without an issue. I am more than certain that if we were to apply all five of the sensors currently on the market (that attach to the helmet shell or strap to it) we would still pass any test.
I encourage NOCSAE and each of the helmet manufacturers to work quickly to facilitate the testing of each of the sensors that are on the market and to provide a “maximum” weight added limit.
Parents will be the ultimate decision makers and will purchase only helmets that are proactive in helping them accomplish their duty as being the ultimate guardians of children at play by letting them monitor when and at what force their child took a powerful blow.
Brooke de Lench
Producer/Director: The Smartest Team: Making High School Football Safer (currently airing on PBS)
Author: Home Team Advantage: The Critical Role of Mothers in Youth Sports (Harper Collins)
This is good information to know and to be clarified. Does it also apply to baseball helmets or just football?
My understanding is all NOCSAE certified stuff